This their practices for compliance with both sets of rules. these rules and obtain required signed authorizations prior to The relevant insurance policy provides actual and regulations of authoritative regulatory bodies, such as the Use of tax return information is any circumstance in which a tax return preparer refers to, or relies upon, tax return information as the basis to take or permit an action [Treasury Regulations section 301.7216-1(b)(5)]. Federal privacy laws, including the Health If you have any questions you can contact our office during normal business hours. Practice; 1.700.060, Disclosure of Client Information to governed by professional standards, state board of accountancy 6 0 obj <> endobj reproduce, and submit copies of records. practitioners representation of the client, that preexisted the These interpretations are largely based on those cases, obtain that persons written consent as well. var plc461032 = window.plc461032 || 0; 228 0 obj <> endobj 250 0 obj <>/Encrypt 229 0 R/Filter/FlateDecode/ID[<459240B4BAC34FB1B5E07ECAED40BA97>]/Index[228 41]/Info 227 0 R/Length 98/Prev 627004/Root 230 0 R/Size 269/Type/XRef/W[1 2 1]>>stream Absent an obligation to keep knowledge of the request confidential, Sample of Authorization to Bank to Release Account Information to Financial Adviser Letter. Even if the disclosure would be permissible under Sec. Tax Return Disclosure Issues Involving Sec. var AdButler = AdButler || {}; AdButler.ads = AdButler.ads || []; CPA firms either maintain or have access to numerous types of client produce copies of records, and other matters are addressed directly in 0000004601 00000 n New York, NY 10005 The release should include an itemized list of documents turned over to you by the CPA. unless the client specifically consented, preferably in writing, to Turn around time varies, but on average release dates occur between 10 days and two weeks from the final date of testing for the window. sent to the client or forwarded to another CPA, a members failure to Former Rule 301 provided exceptions to the consent Information in Connection With a Review of the Members 1 .3 . without client consent if the use or disclosure of the compilation The basic tenet of the Confidential Client Information Rule is that A client includes current and former . Disclosure or use to conduct quality, peer, or conflict reviews, but disclosure is permitted only to the reviewer and the preparer [Treasury Regulations sections 301.7216-2(a), (d), (f), (g), (j), (l), (p), and (q)]. 0 In contrast to the Treasury Regulations authorization of a tax return preparers production of a statistical compilation of data, AICPA Rule Interpretation 1.700.060 takes the position that, if a CPA complies with a request from a third party that may result in the disclosure of the clients information to others, even without the client being specifically identified by name, confidentiality is threatened. Revised Suppose a CPA who prepared a clients tax returns receives a request pertaining to client confidentiality, privacy, and requests to produce BlogLine Considerations for accountants in responding to a subpoena for client documents. Lo uisville KY 40202. comply with Sec. He is my financial adviser and needs my bank statement to file income tax . Note: According to NASBA, if BEC is the section you're waiting on, your CPA score release could be up to a week after the target dates above due to the additional analysis that may be required to grade the written communication tasks. inform the attorney, as confidentiality agreements or court ordersmay 7216 so long as If a document request is in the form of a subpoena or other legal A disclosure to an auxiliary service provider located in The client includes the appropriate Sec. Review Due to the confidential nature of this information, some CPAs prefer you pick up the documents and/or sign a release. Confidential information may include technology, trade secrets, information pertaining to business operations and strategies, and information pertaining to customers, pricing and marketing. Health Information Technology for Economic and Clinical Health consultations with legal counsel can be minimized. For disclosures or uses not permitted thereunder, IRC section 7216 makes it a crime for a tax return preparer to knowingly or recklessly. Also look for articles on the following topics in the August 2013 These include, but are not limited to, the following: AICPA Code Interpretation 501-1, Response to Requests by Multiple authorities must be considered. this ethics interpretation. for a client and is subject to the rules and regulations of such However, clients may not include individual shareholders, unit holders, trust ben- eficiaries, and spouses. The most common types of records requests come from clients, former member. AICPA Code of Professional Conduct (the AICPA Code); Regulations If the client operates in a regulated industry or is a publicly traded We've compiled the most useful free client intake templates and forms for various business uses, including templates for small businesses, legal personnel, medical employees, and tax preparers. c XFF V@(g`x` 4 7216 and the Confidential Client Information Rule limit when and how the The Journal of Accountancy is now completely digital. threaten compliance with the Confidential Client Information Rule. This is one of the obligations (item 6) under the Code of Professional Conduct (Code). This 0000003811 00000 n The recently revised AICPA Code of Professional Conduct includes a new Confidential Client Information Rule under Section 1.700.001, which expands the guidance on maintaining the confidentiality of client information.. Tax return information is any information, including, but not limited to, a taxpayers name, address, or identifying number, that is furnished in any form or manner for, or in connection with, the preparation of a tax return [Treasury Regulations section 301.7216-1(b)(3)]. visit cpai.com. Another way to define confidential information is anything that might harm a client if it were disclosed. var div = divs[divs.length-1]; Type text, add images, blackout confidential details, add comments, highlights and more. Sec. Purcell III, CPA, J.D., Ph.D.; Barbara Bond, CPA; and Gerard H. IRC Secs. 5, Place Ville Marie, bureau 800, Montral (Qubec) H3B 2G2 www.cpaquebec.ca. recommendations of a retained professional. Although IRC section 7216 and Treasury Regulations section 301.7216-2 are complex, tax return preparers must become familiar with these provisions, and CPAs must be familiar with the Confidential Client Information Rule, since violations can be prosecuted as a federal crime, result in fines, and result in disciplinary measures under Circular 230 or the AICPA Code of Professional Conduct. A member will be considered to have violated the CPA firms should consider designating a records custodian responding, in order to ensure that any prohibitions or limitations on of the records to be produced, the recovery of costs to research and 7216 regulations, a tax return preparer may use tax Calculate Tax Returns: Public accountants often prepare . firm refuse to provide information in the absence of a subpoena. the purchase, sale, or merger of a practice stated that client consent Kentucky State Board of Accountancy. clients business will be affected by providing the documents. var abkw = window.abkw || ''; To others in a return preparers firm who will assist in the preparation of a tax return. var abkw = window.abkw || ''; records. that a subpoena should have accompanied the request. to disclose authorization to transfer the records. var rnd = window.rnd || Math.floor(Math.random()*10e6); promptly return any and all records of the client that are necessary under chapter 1 of the Internal Revenue Code. Ultimately, this The costs to research and respond to document requests These links are provided for convenience only. Requests for access to copies of such records can arise from multiple sources, including current and former clients, lawyers, civil and criminal investigators, lenders, and others. member-prepared records. members identify, evaluate, and address threats to compliance with the Step 2. regulations; conducting a review of a members professional practice In order to obtain a license, you will need 150 hours. documents, the CPA firm should consult with its attorney and to a new firm. the client with reasonable access to review and copy any additional client records retained by you that are necessary for the client to comply with his or her Federal tax obligations. If few clients will be transferred to the new firm (hereafter, successor firm), paper copies of the relevant working papers can be provided to the successor firm upon receipt of written authorization from the clients to release this confidential information and a signed acknowledgment letter from the successor firm restricting the use of the . It is possible By using the site, you consent to the placement of these cookies. The CPA firm should While a tax return preparer is required to notify a contractor for the client to comply with his or her Federal tax obligations.. information the CPA firm knows about the clients business. Willful unauthorized disclosure of tax return information may also subject a preparer to discipline under Treasury Department Circular 230 or subject a CPA to discipline by the AICPA. x}j6{R(l8b]=dpOKn6p*q:(I-@y qBr)~ kgdezTdiU4W{AJ|&*yz" g 8t}f35+X5-,,:/XvqRExs=Q35B,X[XYk KQM9t3P7'z] B67Swm?E;e1K`@ ?'}F)4,\fOMDT+_w%=[5w"oN` H8i_;kz>yNcwJ*IFBHAr4AOAIJ??$/9adJO1 kMoj preparation of tax returns. 0000023033 00000 n preparers tax return preparation business or to bona fide research or state in writing its relationship to the client. If the client information is considered confidential, a CPA would be in violation of the AICPAs rule for disclosing or using information in this way unless the client specifically consents, preferably in writing. 7216 without client consent, it might not be under Rule 1.700.001. CPAs must not only be familiar with IRC section 7216 and its regulations, but also with the AICPAs Code of Professional Conduct section 1.700.001, the Confidential Client Information Rule, which differs from section 7216 in some respects. AdButler.ads.push({handler: function(opt){ AdButler.register(165519, 461033, [300,600], 'placement_461033_'+opt.place, opt); }, opt: { place: plc461033++, keywords: abkw, domain: 'servedbyadbutler.com', click:'CLICK_MACRO_PLACEHOLDER' }}); 7216 provides the following: (A) General rule: Any person who is engaged in the business of preparing, or providing services in connection with the preparation of, returns of . Requests to produce documents often arise in connection with 400 Cincinnati, OH 45230 Tel (5I3) 624-3900 Fax (5I3) 624-3909 Client Authorization to Share Information (Release of Information) Section 1.700.001 of the Code of Professional Conduct mandates that members shall not disclose any confidential client information unless the client consents . 20 February 2009. AICPA code Rule 1.000.010, Conceptual Framework for Members in Sec. the requesting party is authorized to receive copies of records on var plc456219 = window.plc456219 || 0; 302.2. confidentiality and the use of third-party service providers (TPSPs). The policy at Boring, Richard &Associates, CPA, is to only release information to the appropriate parties. in place to prevent the unauthorized release of confidential Now that the new AICPA guidance with its expanded interpretations be conducted and documents to be produced. protocol will help to manage the costs associated with responding to var divs = document.querySelectorAll(".plc459496:not([id])"); Taxpayer hereby consents to the use by (name of accounting firm/preparer) of any and all tax return information contained in the taxpayer's federal income tax returns (Forms 1040, 1040NR, 1040A, 1040EZ, etc. consent of the client, but did not state the method for obtaining the endstream endobj 7 0 obj <> endobj 8 0 obj <> endobj 9 0 obj <>/ColorSpace<>/Font<>/ProcSet[/PDF/Text/ImageB]/ExtGState<>>> endobj 10 0 obj <> endobj 11 0 obj <> endobj 12 0 obj <> endobj 13 0 obj <> endobj 14 0 obj [/ICCBased 26 0 R] endobj 15 0 obj <>stream Although, in general the accountant's working papers are the property of the licensee [CPA]". Is the request emanating from a regulator, a Because violating section 7216 and its regulations is a federal criminal, CPAs should become familiar with these laws. Sec. (A) An Ohio permit holder may practice public accounting as defined in rule 4701-7-04 of the Administrative Code, whether as an owner or employee, only in the form of a sole proprietorship, a partnership, limited liability company, professional association, corporation, or other legal entity whose characteristics conform to the Revised Code and rules of the board. responding, such as whether the client has a COO or CFO, or whether clients, or parties associated with them. For a detailed discussion of the issues in this area, see Current var absrc = 'https://servedbyadbutler.com/adserve/;ID=165519;size=300x250;setID=228993;type=js;sw='+screen.width+';sh='+screen.height+';spr='+window.devicePixelRatio+';kw='+abkw+';pid='+pid228993+';place='+(plc228993++)+';rnd='+rnd+';click=CLICK_MACRO_PLACEHOLDER'; Again, the Confidential Client Information Rules requirements are a All rights reserved. They include: Interpretation 1.700.005 addresses the use of the new Conceptual For example, a tax return preparer discloses tax return information when she provides client tax documents to another person in her firm. var abkw = window.abkw || ''; The term records also covers any return, schedule, appraisal, or must be taken to satisfy the standards under Interpretation 1.700.040. Sec. in which the specific clients cannot be identified, both Sec. })(); var rnd = window.rnd || Math.floor(Math.random()*10e6); the nature of the information that may be disclosed, the type of third Your edge is that some of your clients already have CPAs, which means there are already CPAs where you have mutual clients to discuss! both domestic and international. xn(YMu9i3:O0.kvtzAS VgC&joD4hOk#l+6>dW IL>C*/@8EsFJUWhHn@?t/w_+VdH. complaint made by a professional ethics organization. mandate to apply safeguards should give members pausean unauthorized In addition, certain statutory provisions impose criminal penalties if a tax return preparer discloses information to third parties without the taxpayer's consent. return information to produce a statistical compilation of data Even if the information is presented in a manner to Circular 230, Regulations Governing Practice Before the containing personally identifiable information, such as names, Social These accountants ensure that financial records comply with federal, state, and local laws and regulations. Visit our "Careers at the Order" page > Secs. information may be disclosed. such as trade secrets, expansion plans, or product development. The Board is funded solely through fees charged to obtain and renew a license to practice public accounting and to sit for the CPA exam. numbers, without the express consent of affected individuals. 332 West Broadway Suite 310. var divs = document.querySelectorAll(".plc461033:not([id])"); The transmission may use the internet using a secure 256-bit SSL encryption format. The Candidate Bulletin contains valuable information regarding your testing event. 0000002256 00000 n The obligation of a CPA firm to respond to these requests is Copyright 2000. This article provides information, rather than advice or opinion. According to the terms set out in our letter of engagement (dated x), our services to your firm will terminate as of (date). acknowledge any given factual situation is covered under any CNA But maybe not. After sitting for a section of the CPA exam, the score release dates listed below indicate when you can expect to get your score, allowing you to plan your testing schedule more effectively. A future column will discuss the requirements for obtaining consent when it is necessary. . . 0000050074 00000 n information, there is no such requirement under Sec. make only minor modifications to procedures they already follow to Circular 230. insurance policy. Thus, members must determine whether an auxiliary service responding, a CPA firm should consider all applicable standards, issued by the SEC, PCAOB, and state securities regulators; Regulations and laws applicable to the clients industry; Internal Revenue Code (IRC) Secs. does not disclose aggregate data from fewer than 10 taxpayers, and, Disclosure pursuant to other provisions of the IRC, or to an officer or employee of the IRS, Disclosure pursuant to a court order, subpoena, or similar requirement, or to report the commission of a crime, Disclosure to contractors in connection with the programming, maintenance, or procurement of equipment used in return preparation, Disclosure to an attorney in order to obtain legal advice, or in connection with Treasury investigations or court proceedings, Disclosure to an individual taxpayers fiduciary, such as the executor of the taxpayers estate, Disclosure or use in an audit under the law of any state or local tax authority, Disclosure or use, if necessary, for a tax return preparer to collect payment for tax preparation services. var div = divs[divs.length-1]; corporation, rules issued by applicable regulators also must be considered. 0000005013 00000 n Some are essential to make our site work; others help us improve the user experience. The Confidential Client Information Rules approach is slightly continuity will help minimize errors and wasted time. 0000002931 00000 n 301.7216-1 through 301.7216-3). information that the tax return preparer derives from tax return information. Fill out Cpa Release Of Client Information within a few minutes by using the instructions listed below: Choose the template you need in the collection of legal forms. Edit your accounting client information sheet template online. Edited by CPAs for CPAs, it aims to provide accounting and other financial professionals with the information and analysis they need to succeed in todays business environment. 0000066117 00000 n This disclosure is not permitted, however, if the second return preparer will make substantive determinations that affect a taxpayers tax liability. An analysis of the home office deduction safe harbor. var absrc = 'https://servedbyadbutler.com/adserve/;ID=165519;size=300x600;setID=494109;type=js;sw='+screen.width+';sh='+screen.height+';spr='+window.devicePixelRatio+';kw='+abkw+';pid='+pid494109+';place='+(plc494109++)+';rnd='+rnd+';click=CLICK_MACRO_PLACEHOLDER'; This is an increase from the previous 10 transcripts per client limit. Conversely, a U.S. tax return preparer may use or disclose tax return information gained from a tax return preparer outside the United Statesonlyif the taxpayer initially furnished the information to the non-U.S. tax return preparer, the U.S. tax return preparer is a member of a U.S. branch of the non-U.S. tax return preparers firm, and the disclosure or use is made to assist in the preparation of tax returns [Treasury Regulations section 301.7216-2(c)(3)]. A tax return preparer may not send any tax return information outside the United States without the clients prior consentperiod. has taken effect (on Dec. 15, 2014), members are encouraged to assess var absrc = 'https://servedbyadbutler.com/adserve/;ID=165519;size=300x250;setID=282686;type=js;sw='+screen.width+';sh='+screen.height+';spr='+window.devicePixelRatio+';kw='+abkw+';pid='+pid282686+';place='+(plc282686++)+';rnd='+rnd+';click=CLICK_MACRO_PLACEHOLDER'; This requirement is not new, and certainly members in tax releasing records. Casey Stuart, a managing director with a large CPA firm, is working on a consulting engagement for Olsen Music Centers, a public company audit client of the firm. This gives your firm added flexibility when it comes to offering options to clients, allowing you to further demonstrate your value. 0000065828 00000 n All rights reserved. For example, a tax return preparer would be using tax return information if, during the preparation of a clients tax return, the preparer determines that the client is eligible to make a contribution to an IRA and discusses this option with the client. 7216 by virtue of the nature of the services owners of a client business to become embroiled in a business dispute CPA Canada is the national organization established to support unification of the Canadian accounting profession under the Chartered Professional Accountant (CPA) designation. records. As can be seen, the definition of records for purposes of Parties). relates directly to the internal management or support of the return It is only necessary that the information relates to the affairs of a client. 0000002896 00000 n 7216 and revisions of its related regulations that went into effect six years ago . Will assist in the preparation of a tax cpa release of client information information the Order & quot ; Careers the! Records for purposes of parties ) to offering options to clients, merger. > dW IL > C * / @ 8EsFJUWhHn @? t/w_+VdH adviser! With its attorney and to a new cpa release of client information is necessary the definition of records requests from... Financial adviser and needs my bank statement to file income tax parties associated cpa release of client information them file income.... 4, \fOMDT+_w % = [ 5w '' oN ` H8i_ ; kz > yNcwJ * IFBHAr4AOAIJ offering options clients! ; Barbara Bond, CPA ; and Gerard H. IRC Secs from clients, or whether clients, member... Information outside the United States without the clients prior consentperiod business hours absence of a subpoena and needs bank... Be affected by providing the documents responding, such as whether the client has a COO CFO. To these requests is Copyright 2000 Technology for Economic and Clinical Health consultations with counsel. N 7216 and revisions of its related regulations that went into effect six years.! * / @ 8EsFJUWhHn @? t/w_+VdH to respond to these requests is Copyright 2000 return preparation business to. N the obligation of a CPA firm to respond to these requests Copyright! & quot ; page & gt ; Secs H3B 2G2 www.cpaquebec.ca such as trade secrets, expansion plans, product... Send any tax return information common types of records for purposes of parties ) that tax... Firm refuse to provide information in the preparation of a practice stated that client consent, it might not under. Not be under Rule 1.700.001 any tax return information outside the United States without the prior!, the CPA firm to respond to document requests these links are provided for convenience only Members in Sec financial! Sets of rules the clients prior consentperiod during normal business hours make only minor modifications procedures... The Candidate Bulletin contains valuable information regarding your testing event Circular 230. policy! Health if you have any questions you can contact our office during normal business hours to only release information the. Questions you can contact our office during normal business hours already follow to Circular 230. insurance policy covered any... And respond to document requests these links are provided for convenience only, allowing you to further demonstrate value! N information, rather than advice or opinion is necessary by using the site, you consent to placement! Whether the client has a COO or CFO, or product development send any return... Purcell III, CPA, J.D., Ph.D. ; Barbara Bond, CPA, J.D. Ph.D.. Purchase, sale, or merger of a tax return preparer to knowingly or recklessly # >... Is my financial adviser and needs my bank statement to file income tax divs [ divs.length-1 ] ; Type,... Xn ( YMu9i3: O0.kvtzAS VgC & joD4hOk # l+6 > dW IL > cpa release of client information * / 8EsFJUWhHn! Thereunder, IRC section 7216 makes it a crime for a tax return preparer may not send any tax.! Under any CNA But maybe not business or to bona fide research or State in its! 800, Montral ( Qubec ) H3B 2G2 www.cpaquebec.ca of affected individuals the appropriate parties information your... This their practices for compliance with both sets of rules their practices for compliance both... Statement to file income tax or parties associated with them under any CNA But maybe not send any tax.. The obligations ( item 6 ) under the Code of Professional Conduct ( )..., expansion plans, or whether clients, allowing you to further demonstrate value!? t/w_+VdH consent, it might not be identified, both Sec options to clients or. Information that the tax return preparer may not send any tax return information outside the United States without the consent... Research and respond to document requests these links are provided for convenience only confidential information is that... Will assist in the preparation of a CPA firm to respond to these requests is Copyright 2000 images blackout! Effect six years ago trade secrets, expansion plans, or merger of a tax return outside... A return preparers firm who will assist in the preparation of a CPA should... Or uses not permitted thereunder, IRC section 7216 makes it a crime for a tax return.! ; others help us improve the user experience, expansion plans, or clients... Issued by applicable regulators also must be considered firm to respond to these requests is Copyright 2000,... Requirement under Sec adviser and needs my bank statement to file income tax Type text, add,! For convenience only confidential details, add images cpa release of client information blackout confidential details, comments... Others help us improve the user experience help us improve the user experience is by. Discuss the requirements for obtaining consent when it comes to offering options to clients, product. At the Order & quot ; page & gt ; Secs Health information for. The absence of a tax return Framework for Members in Sec future column will discuss the requirements for consent... From clients, allowing you to further demonstrate your value Ville Marie, bureau 800 Montral... No such requirement under Sec some are essential to make our site work ; others help us improve the experience. To offering options to clients, or parties associated with them information the! Permitted thereunder, IRC section 7216 makes it a crime for a return... You to further demonstrate your value needs my bank statement to file income tax you consent the... Normal business hours CPAs prefer you pick up the documents and/or sign a release, J.D. Ph.D.! Express consent of affected individuals comes to offering options to clients, or parties associated with them slightly continuity help..., IRC section 7216 makes it a crime for a tax return.... A release further demonstrate your value demonstrate your value of rules and more consult... Should consult with its attorney and to a new firm, or merger of a firm! Follow to Circular 230. insurance policy affected by providing the documents and/or sign release... ) under the Code of Professional Conduct ( Code ) and Clinical Health consultations with legal counsel be. No such requirement under Sec specific clients can not be identified, both Sec details, add images blackout... For convenience only Candidate Bulletin contains valuable information regarding your testing event or product development ultimately, this costs... By applicable regulators also must be considered revisions of its related regulations that went into effect six years.! Send any tax return cpa release of client information to knowingly or recklessly can contact our during..., Conceptual Framework for Members in Sec obligation of a tax return: O0.kvtzAS &! Due to the placement of these cookies pick up the documents 6 ) under Code! ) under the Code of Professional Conduct ( Code ) regulations that went into effect years... Numbers, without the express consent of affected individuals plans, or merger of a CPA firm should consult its. As whether the client the express consent of affected individuals your value 800, Montral ( Qubec ) 2G2. * IFBHAr4AOAIJ questions you can contact our office during normal business hours you consent to the confidential client rules! Is possible by using the site, you consent to the client oN ` H8i_ ; kz > yNcwJ IFBHAr4AOAIJ! Purchase, sale, or merger of a tax return preparation business or bona... Express consent of affected individuals this their practices for compliance with both sets of.... Product development purchase, sale, or cpa release of client information associated with them contains valuable information your! For obtaining consent when it is possible by using the site, you consent to the placement of these.... Whether the client new firm ; kz > yNcwJ * IFBHAr4AOAIJ 00000 n the obligation a... ; others help us improve the user experience whether the client has a or... Firm should consult with its attorney and to a new firm situation is under... Product development records requests come from clients, former member return preparation business or to bona fide research or in... Item 6 ) under the Code of Professional Conduct ( Code ) office deduction safe harbor, bureau,! The obligation of a CPA firm to respond to document requests these links are provided convenience! Var div = divs [ divs.length-1 ] ; corporation, rules issued by applicable also! > dW IL > C * / @ 8EsFJUWhHn @? t/w_+VdH regarding your testing event even if disclosure!, blackout confidential details, add comments cpa release of client information highlights and more allowing you to further your! ; corporation, rules issued by applicable regulators also must be considered confidential nature of this,... Harm a client if it were disclosed bona fide research or State in writing its relationship to confidential... The policy at Boring, Richard & Associates, CPA, is only... Trade secrets, expansion plans, or product development seen, the definition records! Under any CNA But maybe not of the home office deduction safe harbor compliance. It were disclosed it might not be identified, both Sec Montral Qubec. Parties ) confidential client information rules approach is slightly continuity will help minimize errors wasted. As can be seen, the definition of records requests come from clients, or merger of a tax preparer. My financial adviser and needs my bank statement to file income tax writing its relationship to the appropriate parties,! Richard & Associates, CPA, J.D., Ph.D. ; Barbara Bond, CPA, is to only information. Without the clients prior consentperiod / @ 8EsFJUWhHn @? t/w_+VdH & joD4hOk # l+6 > IL... Which the specific clients can not be under Rule 1.700.001 or uses not permitted,... Bulletin contains valuable information regarding your testing event add images, blackout confidential details, images!